Under the ISM Code, the company must carry out internal safety audits onboard and ashore at intervals not exceeding twelve months, to verify that safety activities follow the safety management system. The Designated Person Ashore is the link between ship and shore, and is usually the person who relies most on what those audits find.
An internal audit can be a genuine health check or a paperwork exercise that leaves everyone falsely reassured. These are the things a DPA should ask for to make sure it is the former.
1. An auditor who is genuinely independent
The ISM Code expects auditors to be independent of the areas they audit, unless the size and nature of the company make that impracticable. A superintendent auditing the ships they look after every day will struggle to see what they have learned to live with. Ask who is auditing, and what they are independent of.
2. Competence that matches the ship
An auditor who has never served on a tanker will miss the subtleties of cargo operations. Ask for auditors with relevant sea time and command or chief engineer experience on the ship type.
3. Coverage of every ISM element
Audits often focus on documents and drills and skim over areas such as the master's responsibility and authority, resources and personnel, and reports and analysis of non-conformities, accidents and hazardous occurrences. Ask for the audit plan in advance and check that it covers all the elements of the Code and the SMS.
4. Evidence, not just existence
"Procedure in place" tells you nothing. Ask the auditor to sample real records against real activity: the last three permits to work, the last cargo operation, the last two drills, a set of maintenance jobs on critical equipment. The audit should test whether the system works, not whether the binder exists.
5. Interviews with the crew
Since SIRE 2.0, vetting inspectors assess how well crews understand and follow procedures. Internal audits should do the same. Ask for structured interviews with officers and ratings across departments, and for the findings that come out of them.
6. Follow-up of previous findings
Recurring findings are the clearest sign that corrective actions treated symptoms instead of causes. Ask the auditor to verify that findings from the last internal audit, external audits, PSC inspections and vetting have been closed effectively, not just signed off.
7. Findings ranked by risk, with root causes
A long flat list of findings is hard to act on. Ask for each finding to be ranked by risk and traced to a root cause, with corrective and preventive actions that address the cause.
8. A report in time to act
An audit report that arrives a month after the auditor leaves has already lost most of its value. Ask for a report within days, and for results to be brought to the attention of the people responsible for the area audited, as the Code requires, and fed into the management review.
The DPA's leverage
The DPA has direct access to the highest level of management for exactly this reason. A well-run internal audit gives the DPA the evidence needed to ask for resources, push for change and show flag, class and vetting inspectors that the system is working.
Navium carries out independent internal ISM, ISPS and navigational audits, onboard or remote, by Master Mariners. See our audit service.